Aug. 21, 2021
Dear Ms. Allison Herren Lee; U.S. Securities and Exchange Commission Thank you for giving me the opportunity to comment on the "Climate Change Disclosures". An increase in sea-levels may financially impact a company. On the other hand CO2 emissions of a company may impact the environment. While the two statements may look alike, they are different and they have differing consequences. Therefore they should be addressed separately. The first is -mainly- about the interests of shareholders, as it directly impacts the financial results and risks of the company. Second is -mainly- about the wider stakeholder group, such as coastal societies ( i.e https://www.bloomberg.com/news/articles/2020-02-03/mapping-migration-in-the-face-of-climate-change ). In order to avoid this ambiguity, I recommend making an explicit distinction between, * Impacts of climate change on a company's operations and * Impacts of company's operations on climate change. Such a distinction will allow companies, as well as shareholders, stakeholders and regulators, to assess the two differing cause and effect flow in a better structured way. Furthermore, I recommend that the reporting of those two perspectives should be done in two separate sections in a report. Once again, thank you for giving this opportunity to comment. Kind regards, Ertan Kucukyalcin Istanbul